Consultation on NSW Animal Welfare Reform - Issues Paper
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Consultation on NSW Animal Welfare
Reform - Issues Paper
26 June 2020
Department of Primary Industries
c/o Animal Welfare
Locked Bag 21
Orange NSW 2800
animalwelfare.submissions@dpi.nsw.gov.au
Contact: David Edney
President, NSW Young Lawyers
Daniel Cung
Chair, NSW Young Lawyers Animal Law Committee
Contributors: Timothy Allen, Stevie Bladen, Emily Hancock, Shar Doudman, Cynthia Lam and Annice Savill
Coordinator: Rishika PaiThe NSW Young Lawyers Animal Law Committee
(Committee) makes the following submission in response to
the NSW Animal Welfare Reform - Issues Paper (Issues
Paper).
NSW Young Lawyers
NSW Young Lawyers is a division of the Law Society of New South Wales. NSW Young Lawyers supports
practitioners in their professional and career development in numerous ways, including by encouraging active
participation in its 15 separate committees, each dedicated to particular areas of practice. Membership is
automatic for all NSW lawyers (solicitors and barristers) under 36 years and/or in their first five years of
practice, as well as law students. NSW Young Lawyers currently has over 15,000 members.
The Committee comprises a group of over 400 members interested in animal protection and laws regulating
the treatment of animals. The Committee aims to raise awareness and provide education to the legal
profession and wider community, while increasing understanding about the importance of protecting animals
from abuse and neglect. A common theme amongst Committee members is a passion and desire to use their
legal skills and the law to improve the protection of animals.
NSWYL Animal Law Committee | Consultation on NSW Animal Welfare Reform - Issues Paper | June 2020
-2-Structure of submission & Summary of Recommendations
The Committee’s submission will address the following questions from the Issues Paper. We also include in
the below table, a summary of the recommendation for each question addressed by the Committee.
Summary of recommendation
Question 1 Is there anything additional to the current Recognition of animal sentience ought to be
objects that should be included in the objects included as an object of all animal welfare laws, as
of new animal welfare laws? has been inserted in the main objects of the Animal
Welfare Act 1992 (ACT).
Question 2 Do you have any comments on the Cruel activities prohibited under the Prevention of
interactions between the Prevention of Cruelty to Animals Act 1979 (NSW) should not be
Cruelty to Animals Act 1979 (NSW), Animal considered a justifiable defence simply by virtue of
Research Act 1985 (NSW), and Exhibited their compliance with the Animals Research Act
Animals Protection Act 1986 (NSW)? 1985 (NSW).
Question 3 Should additional species be included in the The definition of ‘animal’ is unnecessarily narrow as
definition of ‘animal’ and therefore covered it makes arbitrary distinctions that fail to reflect the
by animal welfare provisions (for example, sentience of animals. All sentient species should be
cephalopods, crustaceans in all situations, included in the definition of ‘animal.’
other species)? Why?
Question 4 Should a consistent definition of ‘animal’ be Sentience should be used as the uniform criteria by
used across the Prevention of Cruelty to which ‘animal’ is defined as it will aim to ensure that
Animals Act 1979 (NSW), Animal Research all beings that are capable of suffering are protected
Act 1985 (NSW), and Exhibited Animals from cruelty.
Protection Act 1986 (NSW)? Why?
Question 5 Do you have any comments on how ‘cruelty’ The definition of cruelty should incorporate a
is currently defined within the Prevention of reference to sentience, as it would provide a strong
Cruelty to Animals Act 1979 (NSW)? basis for effective welfare laws by indicating a
reason for the legal protection of animals.
Question 6 Would you support introducing a minimum The Committee supports introducing a minimum
standard of care into the new animal welfare standard of care into the new laws. Introducing a
laws? duty of care is proactive and is a directive which
protects animal welfare, rather than punishing cruel
behaviour.
Question 7 Do you have any comments on using The current ‘fail to provide’ provisions can form a
existing ‘fail to provide’ provisions under the basis of a minimum standard; however, the
Prevention of Cruelty to Animals Act 1979 Committee recommends a number of provisions
(NSW) as a basis for a minimum standard of that ought to be added to the current provisions, to
care? create one duty of care.
Question 8 Do you have any suggestions about how the The definition of pain should be made clearer to
definition of pain could be updated? contemplate both the physical and mental aspects
of pain.
NSWYL Animal Law Committee | Consultation on NSW Animal Welfare Reform - Issues Paper | June 2020
-3-Question 10 Are there any activities currently considered Ideally, all of the activities should be phased out, as
as research or teaching activities under the there is strong evidence to suggest that animals and
Animal Research Act 1985 (NSW) that humans react differently to the same drugs and
should be excluded? If so, why? stimuli. However, until such time, the research
activities and teaching activities should remain in
the Animal Research Act 1985 (NSW) to ensure
they are properly regulated.
Question 11 Are there any additional activities that should The focus should not be on adding further fields of
be considered as research or teaching research to the Animal Research Act 1985 (NSW),
activities under the Animal Research Act but rather, on reducing the amount of research
1985 (NSW)? If so, why? being conducted on animals.
Question 12 Are there any activities currently included in No activities currently included in the definition of
the definition of 'exhibit' in the Exhibited ‘exhibit’ should be excluded.
Animals Protection Act 1986 (NSW) that
should be excluded? If so, why?
Question 13 Are there any additional activities that should The following should be an included activity in the
be included in the definition of 'exhibit’ under definition of ‘exhibit’:
the Exhibited Animals Protection Act 1986
(NSW)? If so, why? 1. Animals exhibited in connection with the sale or
intended sale of an animal; and
2. Establishments which exhibit animals in
connection to their business, such as on
commercial premises which house aquariums,
aviaries or animal pens.
Question 17 Do you have any comments on providing Inspectors ought to have a more proactive role, by
authorised inspectors with powers and tools way of:
(for example, being able to check
compliance with an existing direction) to 1. Making greater use of the non-governmental
provide proactive support to help prevent charitable organisations to contribute to animal
adverse animal welfare outcomes? welfare monitoring and enforcement.
2. Employing proactive mechanisms such as
ongoing monitoring, mandatory educational
programs for offenders, and compliance support.
Question 18 Should the current provisions that require A move towards a risk-based approach to inspector
inspectors under the Animal Research Act qualifications and powers would enable inspectors to
1985 (NSW) to be public servants who are be better equipped to discharge their duties under
also qualified veterinarians be retained, or the Animal Research Act 1985 (NSW).
should they be amended to allow for a more
risk-based approach? Please explain your
answer.
Question 19 Noting the educational focus of Stock The Committee is supportive of extending the use
Welfare Panels, would you support further and remit of Stock Welfare Panels in certain
consideration of how the Stock Welfare circumstances. However, this is subject to
Panel process could be applied to support consideration of the suitability of that mechanism to
better animal welfare outcomes in non- certain animal welfare scenarios and a revision of the
agricultural cases?
NSWYL Animal Law Committee | Consultation on NSW Animal Welfare Reform - Issues Paper | June 2020
-4-provisions governing the constitution of Stock
Welfare Panels.
Question 20 Are there any specific issues you would like A wide range of amendments is required in order to
to raise as we review the penalties for all appropriately remedy the number of inadequacies in
offences under the Prevention of Cruelty to the penalties under the NSW animal welfare regime.
Animals Act 1979 (NSW), Animal Research The Committee makes some specific
Act 1985 (NSW), and Exhibited Animals recommendations.
Protection Act 1986 (NSW)?
Question 21 Would you support consideration of a risk- The Committee supports a risk-based approach to
based approach to licensing under the licensing under both the Animal Research Act 1985
Animal Research Act 1985 (NSW) and/or (NSW) and/or Exhibited Animals Protection Act 1986
Exhibited Animals Protection Act 1986 (NSW), provided this is only the case where
(NSW), where it would not result in protections for animals are not weakened and
weakened protections for animals? Why? resources are allocated to ensure high-risk business
are properly accredited and scrutinised.
Question 22 Which areas within the animal welfare The framework of the Animal Research Act 1985
legislative framework could be improved to (NSW) should be improved by way of clearer
reduce unnecessary red tape or make requirements regarding:
requirements clearer?
1. Reporting requirements and transparency; and
2. Prioritisation of release, rehabilitation and
rehoming of research animals.
The Exhibited Animals Protection Act 1986 (NSW)
could be improved through banning the use of exotic
animals in entertainment.
Question 23 Do you have any comments on what the role The Animal Ethics Committee, Animal Research
of panels and committees should be in Review Panel and the Exhibited Animals Advisory
supporting the new animal welfare legislative Committee should increase the representation of
framework? persons with a background in animal welfare.
NSWYL Animal Law Committee | Consultation on NSW Animal Welfare Reform - Issues Paper | June 2020
-5-Discussion
The Committee comments on the Questions contained in the Issues Paper as follows:
1. Is there anything additional to the current objects that should be included in the objects of
new animal welfare laws?
The Committee submits that recognition of animal sentience ought to be included as an object of all animal
welfare laws. The Committee recognises that non-human animals (animals) are sentient beings by virtue of
their ability to subjectively feel and perceive the world around them. Sentience thus indicates the weight to be
given to their welfare and it is central to understanding how we should treat them.1 The Australian Animal
Welfare Strategy confirms in its National Implementation Plan that ‘sentience is the reason that welfare
matters.’
On 26 September 2019, animal sentience was expressly recognised in the Australian Capital Territory (ACT)
by legislative amendment to the Animal Welfare Act 1992 (ACT). The main objects of that Act now require
recognition of the following:
1. animals are sentient beings that are able to subjectively feel and perceive the world around them; and
2. animals have intrinsic value and deserve to be treated with compassion and have a quality of life that
reflects their intrinsic value; and
3. people have a duty to care for the physical and mental welfare of animals.2
The Committee submits that a similar section on animal sentience be inserted into all the main objectives of
NSW animal law legislation.
The recognition of animal sentience has been shown to play an important role in informing legislative
interpretation.3 This is evident in the case in the European Union, which recognised animal sentience in 1977,
and in doing so created an obligation to afford full regard to the welfare requirements of animals.4
1 National Animal Welfare Advisory Committee “Submission to the Primary Production Committee on the Animal Welfare
Amendment Bill 2013” at [5].
2 Animal Welfare Act 1992 (ACT), s 4A(1).
3 “ACT’s new animal sentience law recognizes an animal’s psychological pain and pleasure, and may lead to better
protections: 3 October 2019, The Conversation https://theconversation.com/acts-new-animal-sentience-law-recognises-
an-animals-psychological-pain-and-pleasure-and-may-lead-to-better-protections-124577
4 Brexit, Article 13, and the debate on recognizing animal sentience: in law, 28 November 2017
https://www.alaw.org.uk/wp-content/uploads/Article-13-Legal-Briefing-Note.pdf
NSWYL Animal Law Committee | Consultation on NSW Animal Welfare Reform - Issues Paper | June 2020
-6-The Committee submits that recognition of animal sentience in animal welfare laws will bring the legislation
into alignment with community values. As early as 2009, Peter Sankoff, an animal protection scholar, observed
that ‘[w]e have formally abandoned the notion that these sentient beings are ‘just’ animals and undeserving of
moral concern... [and that it is likely that] the large majority of people in Australia... believe that animals matter,
and that their welfare is something that is worthy of being considered.’5
The recognition of animal sentience in the objects of NSW animal welfare legislation also reflects global best
practice. Animal sentience was expressly recognised by legislation passed by the French National Assembly
in 2014,6 the New Zealand Parliament in 2015,7 the parliament of the province of Quebec in 2015,8 Colombia
in 2016,9 and Brussels and Slovakia in 2018.10
The Committee submits that the recognition of animals as sentient beings would pave way for more quality
animal welfare by ‘promoting and protecting the welfare of animals, providing for the proper and humane care,
management and treatment of animals, deterring and preventing animal cruelty and the abuse and neglect of
animals’,11 coupled with enacting specific laws that centre around the sentient status of animals, the intrinsic
value of animals, and the duty of care people have for the welfare of animals.
2. Do you have any comments on the interactions between the Prevention of Cruelty to
Animals Act 1979, Animal Research Act 1985, and Exhibited Animals Protection Act 1986?
The Committee submits that cruel activities otherwise prohibited under the Prevention of Cruelty to Animals
Act 1979 (NSW) (POCTA), should not be considered permissible12 simply by virtue of their compliance with
the Animals Research Act 1985 (NSW) (ARA). In particular, the Committee further submits that the benefit
derived from animal research does not justify the suffering caused to animals because animals are sentient
beings that are able to subjectively feel and perceive, inter alia, pain and suffering.
The utility and ethics of animal research has long been debated by the scientific community. In 1991, former
animal researcher, John P. Gluck opined, ‘the use of animals in research should evolve out of a strong sense
5 Peter Sankoff, ‘The Welfare Paradigm: Making the World a Better Place for Animals?’ in Peter Sankoff and Steven
White (eds), Animals Law in Australasia: A New Dialogue (The Federation Press, 2009) 7, 9.
6 French Civil Code, Art. 515-14: “Animals are living beings gifted with sentience. Subject to the laws that protect the
animals, they are subjected to the regime of goods.”
7 Animal Welfare Amendment Act (No 2) 2015 (NSW), s 4.
8 Quebec Civil Code, Art. 898.1: “Animals are not things. They are sentient beings and have biological needs. In addition
to the provisions of special Acts which protect animals, the provisions of this Code and of any other Act concerning
property nonetheless apply to animals.”
9 Colombia Civil code, Art. 655: “Recognizing the quality of sentient beings to animals”.
10 Nicole Pallotta, ‘Brussels Recognizes Animals as Sentient Beings Distinct from Objects’, Animal Legal Defense Fund
(9 December 2018) < https://aldf.org/article/brussels-recognizes-animals-as-sentient-beings-distinct-from-objects/>.
11 Animal Welfare Act 1992 (ACT), s 4A.
12 Prevention of Cruelty to Animals Act 1979 (NSW), s 24(1)(e).
NSWYL Animal Law Committee | Consultation on NSW Animal Welfare Reform - Issues Paper | June 2020
-7-of ethical self-examination. Ethical self-examination involves careful analysis of one’s own personal and
scientific motives. Moreover, it requires a recognition of animal suffering and a satisfactory working through of
that suffering in terms of one’s ethical values’.13
In order to discuss the ethics and utility of animal research, discussion needs to be turned to the arguable
legitimacy of the practice with reference to the intended purpose and the means of animal research. The
intended primary purpose of animal research is directed at and intended to yield benefits for humankind,
specifically for scientific and medical research that leads to medical progress and therefore advantages human
health.14 The particular aim is for animal research to find treatments and cures for human diseases, illness and
conditions, or decrease the suffering of human patients, and consequently, benefit mankind.15 With respect to
the means, the pain and suffering caused to animals is deemed to be legitimate if it is ‘necessary’16 and
proportionate to the end (that is, the purpose) sought to be achieved. Substantial suffering may be inflicted if
there is a ‘necessity for its infliction’17 that ‘can reasonably be said to exist.’18 There is, therefore, an implication
manifested that the greater the legitimacy of the purposes or objects of animal research, then the greater the
scope for the infliction of pain and suffering upon the animal in the means.
With respect to the utility of animal research, there is a general assumption in biomedical research that the
use of animal models can be relied on as predictive of positive health outcomes for humans. However, this
assumption is flawed, as the reality is that there are key physical and biological differences between humans
and animals that impact the reliability of animal models.19 By way of example:
1. Aan animal used for the purposes of medical research for the cure for cancer would be high on the scale
of legitimacy, and so the degree of pain and suffering that can be caused to an animal for that purpose can
be fairly unlimited if there is a strong causal connection and necessity for that pain to produce that end.
However, mouse models used in animal research testing carcinogenicity were orally given (or injected) with
13 John P. Gluck, ‘Animal experiments and animal rights’ (1991) Ethics and Behavior 1.
14 David DeGrazia, 'The Ethics of Animal Research: What are the Prospects for Agreement?' (1999) 8(1) Cambridge
Quarterly of Healthcare Ethics, 23-24.
15 Jean Greek and Ray Greek, 'Is The Use Of Sentient Animals In Basic Research Justifiable?' (2010) 5(14) Philosophy,
Ethics, and Humanities in Medicine.
16 Ford v Wiley (1889) 23 QBD 203, 219-220 (Hawkins J).
17 Ibid.
18 Ibid.
19 Peter Radan, ‘Antivivisection and Charity’ (2013) 35(3) Sydney Law Review, 535; Andre Menache and Ray Greek,
‘Systematic Reviews of Animal Models: Methodology versus Epistemology’ (2013) 10(3) International Journal of Medical
Sciences; Peter Tatchell, Why Animal Research is Bad Science (New Statesman, 2004), 18-19; Annalea Pippus,
Lawrence A Hansen and Ray Greek, ‘The Nuremberg Code Subverts Human Health And Safety By Requiring Animal
Modeling’ (2012) 13(16) BMC Medical Ethics.
NSWYL Animal Law Committee | Consultation on NSW Animal Welfare Reform - Issues Paper | June 2020
-8-a carcinogen to induce cancer for the purposes of finding a cure for cancer.20 While the mice were cured of
the cancer, it has not worked in humans.21
2. Animal research for the purpose of finding a safe and effective vaccine for curing and preventing HIV/AIDS
would be high on scale of legitimacy due to its overwhelming public health impact.22 However, when
chimpanzees were initially infecting chimpanzees with the HIV virus, they did not experience influenza-like
symptoms of the infection as humans do, and as such, their use in the research was proven to be
unnecessary and unhelpful.23 As such, recent alternate research developments have ‘rendered
chimpanzees largely unnecessary as research subjects.’24
3. TGN 1412, an immunomodulatory drug, caused ‘catastrophic systemic organ failure’ in the volunteers it
was injected into in 2006. No such effect was found during previous research on rats, mice, rabbits and
non-human primates.25
4. A vaccine, first tested on animals, was found to expose women to increased risks of developing stroke and
breast cancer.26 This was not found in the mice or non-human primates that it was first tested on.27
Overall, ‘unanticipated human toxicity’ is responsible for the failure of almost half of clinical trials of new
pharmaceuticals.28 This reveals that while chemicals, pharmaceuticals and procedures can have one effect in
animals, the outcome can be very different and at times, detrimental, to humans.29
These are only a few examples amongst many which exemplify the difficulty in making inferences about what
will happen to humans based on conclusions reached from animal-based research. Indicative of a (slow but
gradual) shift from the consequentialist thinking that animal suffering can justify the means, as discussed
above, are also evident in the developments in Australia to ban cosmetic testings on animals,30 as well as
20 Annapoorni Rangarajan and Robert A Weinberg, ‘Comparative Biology Of Mouse Versus Human Cells: Modelling
Human Cancer In Mice’ (2013) 3(12) Nature, 952-9; Kenneth R Hess, 'Statistical Design Considerations In Animal
Studies Published Recently In Cancer Research' (2011) 71(2) Cancer Research, 625.
21 Ibid.
22 Lena J Gamble and Qiana L Matthews, ‘Current Progress In The Development Of A Prophylactic Vaccine For HIV-1’
(2010) 5 National Center for Biotechnology Information; Tania Rivera-Hernandez, ‘The Contribution of Non-human
Primate Models to the Development of Human Vaccines’ (2014) 19 Discovery Medicine.
23 Robert C Jones, ‘A Review of the Institute of Medicine’s Analysis of using Chimpanzees in Biomedical Research’
(2013) 20(2) Science and Engineering Ethics, 481-504; Andre Menache and Ray Greek, ‘Systematic Reviews of Animal
Models: Methodology versus Epistemology’ (2013) 10(3) International Journal of Medical Sciences; Lena J Gamble and
Qiana L Matthews, ‘Current Progress In The Development Of A Prophylactic Vaccine For HIV-1’ (2010) 5 National
Center for Biotechnology Information.
24 Institute of Medicine of the National Academies, Chimpanzees in Biomedical and Behavioural Research, Assessing
the Necessity (15 December 2011).
25The Flaws and Human Harms Article, 412-413.
26The Flaws and Human Harms Article, 412-413.
27 The Flaws and Human Harms Article, 412-413.
28 Limitations Study, 846.
29 Limitations Study, 846.
30 Department of Health, Ban on the use of animal test data for cosmetics (24 April 2020), Australia Government
.
NSWYL Animal Law Committee | Consultation on NSW Animal Welfare Reform - Issues Paper | June 2020
-9-calling for more transparency for use of animals in medical testing.31. This is further evidence of the failure of
animal research and testing to produce any predictive value for human trials, thereby illustrating the
unnecessary suffering that animals go through for no scientific progress.32
With respect to the ethics of animal research, significant distress and pain to the animal is caused. Various
substantial stressors exist in laboratory settings for animal subjects.33 Stressors can be as a result of the
trauma in animal subjects captured from the wild to supply laboratory or breeding centres, or from unnatural
laboratory housing and environments, or simply because of the nature of the animal research method, whether
it is invasive and/or routinely by handling, gavaging and blood sampling.34 Whether testing is conducted into
their eyes, down their throats or onto their sensitive exposed skin; rabbits, guinea pigs, mice and rats are
regularly subjected to negative side effects as a result of chemical research.35 Certain medical treatments
have caused liver tumours and toxicity in the animals the drugs were first tested on.36 Psychological
experiments also have significant health impacts on animals being tested on. One psychological study, which
involved isolating primates, led to them engaging in harmful behaviour such as self-mutilation, biting and
ripping out their hair.37 Exposure to abnormal conditions also has significant health impacts. Animals in
confinement suffer stress and anxiety, and physical declines in health.38 Unsurprisingly, electric shock
research can result in significant pain to the animal.39 All of the mentioned research and teaching activities
have the potential to cause serious health repercussions. In the Committee’s submission, these consequences
to the physical and mental welfare of animals are unacceptable noting the sentient nature of animals by virtue
of their ability to subjectively feel and perceive the world around them.40
While NSW leads Australia in having a separate law for animal research, the ARA directs the relevant authority
back to the Australian Code of Practice for the Care and Use of Animals for Scientific Purposes (Code), which
31 Calla Wahlquist, Sydney baboon escape: the questions that remain (26 February 2020), The Guardian
; Natalie O’Brien, Millions of
animals around Australia subjected to experiments and surgery (30 January 2016), Sydney Morning Herald
; Humane Research Australia (2016) .
32 Michelle Kretzer, Experiments on animals fail 90% of the time. Why are they still done? (31 January 2018), People for
the Ethical Treatment of Animals .
33 Andrew Knight, The Costs and Benefits of Animal Experiments (Palgrave Macmillan, 2011), 42.
34 Ibid.
35 Peta Australia, How Cruelty-Free are your Cosmetics? .
36 Akhtar, Aysha, ‘The Flaws and Human Harms of Animal Experimentation’ (2015) 24 Cambridge Quarterly of
Healthcare Ethics 407–419 (‘The Flaws and Human Harms Article’).
37McLeod, S. A, ‘Attachment theory’ (2017) Simply Psychology. and
Katherine Bayne, ‘Potential for Unintended Consequences of Environmental Enrichment’ (2005) 46(2) 130. Accessed
from
38 The Flaws and Human Harms Article, 408.
39 Penn State Animal Resource Program, Use of Electric Shock in Research Animals, (30 April 2014)
https://www.research.psu.edu/arp/experimental-guidelines/rodent-behavioral-tests-1/use-of-electric-shock-in-research-
animals.html
40 See the Committee’s response to Question 1 of this submission.
NSWYL Animal Law Committee | Consultation on NSW Animal Welfare Reform - Issues Paper | June 2020
-10-outlines general principles in which experiments should take place. The categories have been criticised by
Katrina Sharman, the first Corporate Counsel of Voiceless: the animal protection institute, as being ‘so broad
that it is hard to think of an example of an experiment that would not fall within them.’41 Katrina also comments
that ‘while the Code does seem to require the balancing of the predicted scientific/educational value of that
project with its effects on animal welfare … it is difficult to see how animals could emerge victorious from this
cost benefit analysis given the widespread faith in the current test model and the classification of animals as
mere legal ‘things’.42
The Committee submits that available alternatives to animal research are often a more sophisticated way to
attempt to address a particular scientific question, and often more efficient, accurate than the means they
replace.43 Human clinical studies, such as for micro-dosing purposes, can be used whereby (voluntary) human
participants are given ‘low quantities of a drug to test the effects on the body on the cellular level’44 without it
affecting the entire human body system. Further examples of alternatives include using human stem cells for
basic research, or in vitro (test tube) research using human tissue.45 Other effective alternatives include cell,
tissue and organ engineering which can be used for testing drug toxicity; or using human bodies donated to
science for the purposes of sourcing information about the human body, disease processes and other medical
questions.46 The implementation of such alternative methods would better achieve the objectives of POCTA
by preventing cruelty to animals, and promoting the welfare of animals by ‘requiring a person in charge of an
animal to provide care for the animal, and (to treat the animal in a humane manner, and to ensure the welfare
of the animal’.47
The Committee considers the defences set out in POCTA run counter to the express objects of the Act, and
that allowing defences to cruelty as per the ARA appears to protect the interest of scientific research over
animal welfare despite the available alternatives to animal research which do not gamble scientific integrity
and ethics.
41 K, Sharman, ‘Opening the laboratory door: national and international legal responsibilities for the use of animals in
scientific research – an Australian perspective’ (2006) Journal of Animal Law 2, 67 at 31.
42 Ibid.
43 Katrina Sharman, 'Opening the Laboratory Door: National and International Legal Responsibilities for the Use of
Animals in Scientific Research' (2006) 2 Journal of Animal Law, 67; David DeGrazia, 'The Ethics of Animal Research:
What are the Prospects for Agreement?' (1999) 8(1) Cambridge Quarterly of Healthcare Ethics, 28
44 Peter Tatchell, Why Animal Research is Bad Science (New Statesman, 2004), 19.
45 Jean Greek and Ray Greek, 'Is The Use Of Sentient Animals In Basic Research Justifiable?' (2010) 5(14) Philosophy,
Ethics, and Humanities in Medicine, 12; David DeGrazia, 'The Ethics of Animal Research: What are the Prospects for
Agreement?' (1999) 8(1) Cambridge Quarterly of Healthcare Ethics, 28.
46 Peter Tatchell, Why Animal Research is Bad Science (New Statesman, 2004), 19; David DeGrazia, 'The Ethics of
Animal Research: What are the Prospects for Agreement?' (1999) 8(1) Cambridge Quarterly of Healthcare Ethics, 28;
Jean Greek and Ray Greek, 'Is The Use Of Sentient Animals In Basic Research Justifiable?' (2010) 5(14) Philosophy,
Ethics, and Humanities in Medicine, 12.
47 Prevention of Cruelty to Animals Act 1979 (NSW), s 3.
NSWYL Animal Law Committee | Consultation on NSW Animal Welfare Reform - Issues Paper | June 2020
-11-3. Should additional species be included in the definition of ‘animal’ and therefore covered by
animal welfare provisions (for example, cephalopods, crustaceans in all situations, other
species)? Why?
The Committee’s view is that the definition of ‘animal’ is unnecessarily narrow.48 It makes arbitrary distinctions
that fail to reflect current scientific knowledge regarding the sentience of animals.49 The Committee submits
that all sentient species should be included in the definition of ‘animal.’
Cephalopods have the capacity to experience pain and suffering through the free nerve endings in their skin.50
Their complex nerve system, display of advanced behaviours and documented intelligence51 all suggest that
animal welfare legislation should extend to these animals.
Protection should also extend to crustaceans in all situations. The physiology of a crustacean does not change
whether they are killed on a boat or in a building or place.52 While some argue that a crustacean’s sentience
is not conclusively established, this should be answered by applying the precautionary principle pending further
evidence.53 In this respect, the National Aquaculture Council Inc has already recognised that crustaceans
experience pain by issuing guidelines for their humane killing.54
Octopus, squid, cuttlefish, lobster, crab and crayfish in particular need urgent legal protection because they
are used widely for human consumption as fishing bait and in scientific research.55 During these processes,
they are prone to stress or injury during catching, handling, storing and killing.56
48 Current definition of “animal” as stated in POCTA is:
(a) a member of a vertebrate species including any:
(i) amphibian, or
(ii) bird, or
(iii) fish, or
(iv) mammal (other than a human being), or
(v) reptile, or
(b) a crustacean but only when at a building or place (such as a restaurant) where food is prepared or offered for
consumption by retail sale in the building or place.
49 The Animal Law Institute, Submission No 25 to the Social Policy Scrutiny Committee, Inquiry into the Animal
Protection Bill (9 March 2018) 2.
50 N.A. Moltschaniwskyj et al, ‘Ethical and welfare considerations when using cephalopods as experimental animals’
(2017) 17 Reviews in Fish Biology and Fisheries 455, 457.
51 Bernd Ulrich Budelmann, ‘The cephalopod nervous system: what evolution has made of the molluscan design’ in O.
Breidback and W. Kutsch (eds), The Nervous Systems of Invertebrates: An Evolutionary and Comparative Approach’
(Birkhauser, 1995) 115.
52 Australian Veterinary Association, Submission No 32 to the Social Policy Scrutiny Committee, Inquiry into the Animal
Protection Bill (2018) 3.
53 Advocates for Animals, Cephalopods and Decapod Crustaceans: Their capacity to experience pain and suffering
(Report, 2005) 5.
54 National Aquaculture Council Inc, Aquatic Animal Welfare Guidelines: Guidelines on welfare of fish and crustaceans in
aquaculture and/or in live holding systems for human consumption (Report, 31 March 2004).
55 Advocates for Animals, Cephalopods and Decapod Crustaceans: Their capacity to experience pain and suffering
(Report, 2005) 3.
56 Ibid.
NSWYL Animal Law Committee | Consultation on NSW Animal Welfare Reform - Issues Paper | June 2020
-12-The Committee submits that any argument that including crustaceans and cephalopods will limit fishing
practices, is not supported by biological science as discussed above. Appropriate exemptions can be included
for legitimate fishing. This is how Queensland, Victoria and Tasmania aim to protect fishing activities whilst
also guarding sentient animals from cruelty.57 Furthermore, NSW and the ACT already take this approach to
fish.58 NSW has a thriving fishing industry, both commercial and recreational, which is not inhibited by the
inclusion of fish in welfare laws.59
In terms of cross-State fishing practices, it is logical for NSW to adopt a definition of ‘animal’ which is consistent
with jurisdictions that already afford protection to these additional species. For example, cephalopods are
protected in the Northern Territory (NT), Queensland and Tasmania, while crustaceans have protection at all
times in NT and Victoria. This would make the legislation nationally consistent.
4. Should a consistent definition of ‘animal’ be used across the Prevention of Cruelty to
Animals Act 1979, Animal Research Act 1985, and Exhibited Animals Protection Act 1986?
Why?
Sentient species should be protected from cruelty, regardless of the way in which they live or are kept.60 It is
submitted that using sentience as the uniform criteria by which ‘animal’ is defined and therefore protected
across all NSW legislation provides a clear and stable parameter, aiming to ensure that all beings that are
capable of suffering are protected from cruelty regardless of their function, use or cognitive ability.61 Failure to
achieve uniformity essentially undermines the rationale of the law.62 It is a form of speciesism63 to say that
some animals deserve protection all the time, and others do not; for example, when it relates to entertainment
or research.64
The Committee submits that a consistent definition would harmonise NSW’s conflicting laws, both within NSW
and with other states, and reflect the community’s position. Benefits include consistency in the obligations,
enforcement, prosecution, and sentencing of offences. This will, in the view of the Committee, allow greater
57 RSPCA, Submission No 28 to the Social Policy Scrutiny Committee, Inquiry into the Animal Protection Bill (9 March
2018) 5.
58 Ibid.
59 Ibid.
60 Animals Australia, Submission No 17 to the Social Policy Scrutiny Committee, Inquiry into the Animal Protection Bill (8
March 2018) 3.
61 World Society for the Protection of Animals, Acknowledging sentience: giving meaning to animal welfare (Report,
September 2012) 3.
62 Ibid.
63 Speciesism is discrimination which involves treating members of one species as morally more important than
members of other species.
64 Ibid.
NSWYL Animal Law Committee | Consultation on NSW Animal Welfare Reform - Issues Paper | June 2020
-13-levels of protection for all animals. Having a consistent definition of animal would also streamline the
opportunities for reform as community expectations develop over time.65
In particular, cephalopods are already protected in the Australian Code of Practice for the Care and Use of
Animals for Scientific Purposes, and therefore, should be incorporated at least in the ARA and preferably
across all three Acts.
Further, retaining inconsistent definitions is likely to make it difficult for an individual to know whether particular
conduct in relation to a particular animal amounts to an offence. Mistaken beliefs about whether an animal is
protected could accordingly result in unnecessary harm coming to an animal.
5. Do you have any comments on how ‘cruelty’ is currently defined within the Prevention of
Cruelty to Animals Act 1979?
The definition of cruelty66 should incorporate a reference to sentience, as referred to above. This would provide
a strong basis for effective welfare laws by indicating a reason for the legal protection of animals.
Legal recognition of sentience also helps separate animals from objects, which do not feel or perceive
anything. Although animals currently have the legal status of property, sentience emphasises their intrinsic
value and special status. Public morality requires the clear distinction in law of the welfare requirements of
animals as opposed to objects. A reference to sentience provides this symbolic gesture.67
Recent amendments to Section 6A of the Animal Welfare Act 1992 (ACT) have changed the definition of
cruelty as follows [emphasis added]:
‘… doing, or not doing, something to an animal that causes, or is likely to cause, injury, pain, stress
or death…’
The recognition of sentience through reference to pain and stress should be adopted in NSW. Pairing this with
an explicit reference to the concept of sentience in the Objects of that Act (as it is in the ACT) will set a clear
spirit for the POCTA.
65 Voiceless, Submission No 8 to the Senate Rural and Regional Affairs and Transport Committee, Inquiry into the Voice
for Animals (Independent Office of Animal Welfare) Bill 2015 (14 August 2015) 4.
66 Current definition of “cruelty” as stated in s 4(2) of POCTA is:
(2) For the purposes of this Act, a reference to an act of cruelty committed upon an animal includes a reference to any
act or omission as a consequence of which the animal is unreasonably, unnecessarily or unjustifiably:
(a) beaten, kicked, killed, wounded, pinioned, mutilated, maimed, abused, tormented, tortured, terrified or infuriated,
(b) over-loaded, over-worked, over-driven, over-ridden or over-used,
(c) exposed to excessive heat or excessive cold, or
(d) inflicted with pain.
67 RSPCA, Submission No 28 to the Social Policy Scrutiny Committee, Inquiry into the Animal Protection Bill (9 March
2018) 4.
NSWYL Animal Law Committee | Consultation on NSW Animal Welfare Reform - Issues Paper | June 2020
-14-The definition section of an Act is used for primary interpretation and provides guidance on the broader intent.
When a defined word is used in the text of legislation, the words of the definition will be read into the substantive
enactment and is construed accordingly.68 Thus the effect of recognising sentience in the definition of cruelty
is that it will indicate the spirit of the legislation and inform interpretation of the operative provisions.
6. Would you support introducing a minimum standard of care into the new animal welfare
laws?
The Committee supports introducing a minimum standard of care into the new laws.
In protecting animal welfare, the Issues Paper correctly highlights the importance of introducing proactive
language, rather than reactive. The use of ‘fail to provide’ provisions in POCTA69 means that it is geared
towards punishing behaviour that has reached the stage of failing to provide for the animal. That is, it is reacting
to poor behaviour, rather than looking to prevent it in the first place. Conversely, introducing a duty of care is
proactive and is a directive which protects animal welfare, rather than punishing cruel behaviour.
As highlighted in the Issues Paper, it is imperative that the language used in legislation is precise and the law
well defined;70 the risk of not doing so being that it more people disobey the duty. The Committee submits that
using words such as ‘reasonable’71 or ‘appropriate’72 to describe a duty to care for animals poses a problem.
These terms are subjective and vague, and in turn do not necessitate a strict standard to be met. In some
attempt to resolve the ambiguity, the NSW legislation sets the period of 24 hours as a marker (for instance
failing to provide an animal with food in 24 hours is evidence of failing to provide sufficient food).73 Setting a
timeframe is one way to set the standard. Another way is to strictly define who or what determines what is
‘reasonable’ or ‘appropriate.’ New Zealand has done this, in that the obligation to ensure animals is met when
their needs is satisfied according to ‘scientific knowledge.’ 74 Ideally, a body or organisation that is purely
focused on, and knowledgeable in, animal welfare would be the most appropriate at assessing and setting the
standard of what is a ‘reasonable’ provision of animal care. Such bodies could include the RSPCA, Animal
Welfare League NSW, the International Fund for Animal Welfare, and World League for Protection of Animals.
The Committee supports introducing a minimum standard of care to the new animal welfare laws and notes
the importance of setting an objective standard which the provision of animal welfare must meet.
68 Kelly v R [2004] HCA 12; (2004) 218 CLR 216 at [103].
69 Prevention of Cruelty to Animals Act 1979 (NSW) ss 8 & 9.
70 Animal Protection Index, Austria Recognition of Animal Sentience and Prohibition of Animal Suffering (10 March 2020)
.
71 Animal Care & Protection Act 2001 (QLD) s 17 and Prevention of Cruelty to Animals Act 1979 (NSW) ss 5(3)(a) & (b)
and 8(1).
72 Animal Protection Act 2018 (NT) s 6(b) s 6(1)(a-g).
73 Prevention of Cruelty to Animals Act 1979 (NSW) s 8(3).
74 Animal Welfare Act 1999 (NZ) s 10.
NSWYL Animal Law Committee | Consultation on NSW Animal Welfare Reform - Issues Paper | June 2020
-15-7. Do you have any comments on using existing ‘fail to provide’ provisions under the
Prevention of Cruelty to Animals Act 1979 as a basis for a minimum standard of care?
The Committee proposes that the current ‘fail to provide’ provisions can form a basis of a minimum standard,
but that it needs to be further developed.
It is important that the below provisions, currently included in POCTA, form the basis of the minimum standard:
1. The provision of food, water and shelter;75
2. The provision that animals be exercised;76
3. The provision of veterinarian treatment;77 and
4. The provision for the alleviation of pain.78
The Committee recommends that the following additions be implemented together with the above provisions,
to create the minimum duty of care:
1. Clean and hygienic living conditions - That the provision dealing with shelter also covers living conditions
(as exists in the NT legislation). 79 This is so that all living arrangements can be covered. Including this
provision also requires that the shelter and living conditions are clean and hygienic (as appears in the
ACT animal welfare legislation).80
2. Confined or restrained - That a provision be included that requires that an animal not be confined or
restrained unreasonably (see NT’s Animal Protection Act). 81 This could be added to the current provision
about tethering, in POCTA.82
3. Handled - That a provision be added that mandates that an animal when required to be physically handled,
be handled appropriately and with care (see NT’s Animal Protection Act).83 This means in a way that does
not cause unnecessary distress or pain (see New Zealand’s Animal Welfare Act.)84
75 Prevention of Cruelty to Animals Act 1979 (NSW) s 8(1).
76 Prevention of Cruelty to Animals Act 1979 (NSW) s 9.
77 Prevention of Cruelty to Animals Act 1979 (NSW) s 5(3)(c).
78 Prevention of Cruelty to Animals Act 1979 (NSW) s5(3)(b).
79 Animal Protection Act 2018 (NT) s 6(b).
80 Animal Welfare Act 1992 (ACT) s 6B(1)(e).
81 Animal Protection Act 2018 (NT) ss 6(f) & 4 definitions (“confine”).
82 Prevention of Cruelty to Animals Act 1979 (NSW) s 10(1).
83 Animal Protection Act 2018 (NT) s 6(e).
84 Animal Welfare Act 1999 (NZ) ss 10 & 4(d).
NSWYL Animal Law Committee | Consultation on NSW Animal Welfare Reform - Issues Paper | June 2020
-16-4. Groomed and maintained - That a duty to groom and maintain the animal be added (see NT’s Animal
Welfare Act).85 Animals can suffer heat stress, painful skin conditions, infestations of fleas and ticks and
infection if not properly groomed.86
5. Display normal patterns of behaviour - That a duty to allow an animal to display normal patterns of
behaviour be added. This has been implemented in Queensland’s,87 New Zealand’s 88 and the United
Kingdom’s89 various animal welfare legislation. Research evidences how crucial it is to an animal’s welfare
to be able to express their natural patterns of behaviour.90
6. Socialisation - That a provision be included which satisfies an animal’s need for regular socialisation, be
implemented (for an example see Austria’s animal protection laws).91 Socialisation should encompass
contact with people, other animals, and different environments.92 Research demonstrates that
socialisation is an inherent part of maintaining an animal’s welfare.93
The Committee recommends that the above provisions be added to current ‘failure to provide’ provisions, to
create one duty of care.
8. Do you have any suggestions about how the definition of pain could be updated?
The Committee submits that the definition of pain should be made clearer to contemplate both the physical
and mental aspects of pain. The current definition, and the indicators of suffering and distress, fail to refer to
psychological suffering. The Committee submits that this is too narrow and ignores an entire element of an
animal’s sentient experience. The Five Freedoms acknowledge the potential for mental suffering and refer to
ensuring conditions and treatment which avoid this.94 To the extent that animals are under human control,
85 Animal Protection Act 2018 (NT) s 6B(1)(f).
86 RSPCA Victoria RSPCA, Benefits of Grooming, (2020)< https://rspcavic.org/health-and-behaviour/tips-for-a-happy-
pet-and-owner/benefits-of-grooming>.
87 Animal Care & Protection Act 2001 (QLD) s 9(a)(iii).
88 Animal Welfare Act 1999 (NZ) s 10(c).
89 Animal Welfare Act 2006 (UK) s 9(2)(c).
90 X Manteca, E Mainau, D Temple, ‘What is Animal Welfare? The Farm Animal Welfare Fact Sheet,’ Farm Animal
Welfare Education Centre (June 2012) < https://www.fawec.org/en/fact-sheets/28-general-welfare/106-what-is-animal-
welfare>.
91 Animal Welfare Act 2004 (Austria) article 13.
92 JSJ Odendaal, ‘Science based assessment of animal welfare: companion animals’ (2005) Scientific and Technical
Review of the Office of Epizoötics (‘Science based assessment of animal welfare article’) 21.
93 Science based assessment of animal welfare article, 20.
94 The Five Freedoms include freedom from hunger and thirst; from discomfort; from pain, injury or disease; freedom to
express normal behaviour; and freedom from fear and distress. See RSPCA, ‘What are the Five Freedoms of animal
welfare?’ (2019) .
NSWYL Animal Law Committee | Consultation on NSW Animal Welfare Reform - Issues Paper | June 2020
-17-humans are obligated to uphold these principles.95 Their recognition is central to achieving good animal
welfare.96
The importance of clarifying the definition is shown by the term ‘pain’ being used regularly throughout POCTA
in reference to offences. Failing to recognise psychological pain equates to a loss of enforcement; it limits the
contexts in which causing pain is a punishable offence to instances where an animal suffers demonstrable
physical pain.97 The expansion of the definition would ensure Courts do not give the term ‘pain’ an
unreasonably restrictive meaning.98
Psychological pain is more difficult to identify due to the lack of visible symptoms, and also differs across
specie. This may make it challenging to enforce consistently and objectively. To counteract this, psychological
pain should be measured by behavioural indicators. The Animal Welfare Act 2002 (WA) refers to harm as
including distress ‘evidenced by severe, abnormal physiological or behavioural reactions.’ This alludes to
psychological pain and, importantly, can apply differentially to all species, depending on what their ‘normal’
behaviour would be.
If anything, the difficulty with identifying mental suffering is all the more reason for it to be included. It is
important that POCTA alerts the public to ‘unseen’ suffering, provides a reason for inspectors to undergo
further training to recognise this form of pain, and ensures offenders face penalties. In addition, the expanded
definition could force individuals to pay greater attention to the physical confines of their animals; environment
being necessarily connected to mental wellbeing.
10. Are there any activities currently considered as research or teaching activities under the
Animal Research Act 1985 that should be excluded? If so, why?
It is the Committee’s position that none of the activities be excluded for the time being. If the activities are
excluded from the list of ‘research or teaching activities,’ the Committee is concerned that they will continue,
unchecked and unregulated. This is problematic, since all of the activities currently conducted for the purposes
of ‘research or testing,’ have drastic physical and emotional repercussions on the animals used. Ideally, the
Committee submits that all of the activities should be phased out, as there is strong evidence to suggest that
animals and humans react differently to the same drugs and stimuli as discussed above. However, until such
95 Lawyers for Animals, Submission No 34 to the Social Policy Scrutiny Committee, Inquiry into the Animal Protection Bill
(20 March 2018) 4.
96 Explanatory Statement, Animal Welfare Legislation Amendment Bill 2019 (ACT) 2.
97 Animals Australia, Submission No 17 to the Social Policy Scrutiny Committee, Inquiry into the Animal Protection Bill (8
March 2018) 3.
98 RSPCA, Animal Welfare Legislation Amendment Bill 2019 (Comments, 8 February 2019) 7
.
NSWYL Animal Law Committee | Consultation on NSW Animal Welfare Reform - Issues Paper | June 2020
-18-time, the Committee suggests that the research activities and teaching activities remain in the ARA to ensure
they are properly regulated.
The Committee has set out in detail in its response to Question 2 above, the flawed assumptions about animal
testing and its severely detrimental effects on animals. Accordingly, in the Committee’s submission, must
remain heavily regulated under the ARA. In light of both the poor results of animal testing for research, and
the significant harm to the animal subjects caused by all current research and teaching activities as defined in
the ARA, it must remain heavily regulated. Looking forward, the Committee suggests that the new welfare
regulations encourage a move away from, and ban of, testing on animals, to favour alternative and more
effective methods of research and teaching.
11. Are there any additional activities that should be considered as research or teaching
activities under the Animal Research Act 1985? If so, why?
The Committee submits that the focus should not be on adding further fields of research to the ARA, but rather,
on reducing and phasing out research being conducted on animals, as submitted above. It is recommended
that a similar provision to what is in Sweden’s animal welfare laws99 be implemented in NSW animal welfare
legislation. This would enforce the position that animals should not be used for the purpose of research or
teaching activities, if there is expert evidence identifying an alternative which achieves the same purpose.100
There is growing evidence of promising alternatives to animal research101 which are more reliable and less
costly as animal research.102 These substitute methods are being embraced by countries around the world.
The National Committee for the Protection of Animals in the Netherlands is working towards safely eliminating
the testing of ‘chemicals, food ingredients, pesticides and veterinary medicines’ on animals by 2025.103 It is
promising that federally, Australia is moving towards the banning of animal testing for example by way of the
introduction of The Industrial Chemicals Act 2019. It is recommended that changes be made to NSW animal
welfare legislation that echoes this changing sentiment and shift away from animal research, to focus on other
available research options.
99 Experiments on Animals Act 1977 (Sweden) article 10 (accessed at
).
100 Experiments on Animals Act 1977 (Sweden) article 10 (accessed at
).
101 For alternatives, see:
- Cruelty Free International, (April 2018) ‘Alternatives to Animal Testing’, ;
- Van Norman article p 851; and
- The Humane Society of the United States, ‘Alternatives to animal tests’, (2020)
102 The Humane Society of the United States, ‘Alternatives to animal tests’, (2020)
103 Animal Protection Index, Netherlands Recognition of Animal Sentience and Prohibition of Animal Suffering (10 March
2020) .
NSWYL Animal Law Committee | Consultation on NSW Animal Welfare Reform - Issues Paper | June 2020
-19-12. Are there any activities currently included in the definition of 'exhibit' in the Exhibited
Animals Protection Act 1986 that should be excluded? If so, why?
The Committee submits that no activities currently included in the definition of ‘exhibit’ should be excluded,
and proposes to include more activities as outlined in the Committee’s answer to Question 13 below.
13. Are there any additional activities that should be included in the definition of 'exhibit’ under
the Exhibited Animals Protection Act 1986? If so, why?
The Committee proposes that:
1. animals exhibited in connection with the sale or intended sale of an animal should be an included activity
in the definition, and not included as an exemption to the definition as it is currently; and104
2. establishments which exhibit animals in connection to their business, such as on commercial premises
which house aquariums, aviaries or animal pens, should also be subject to licensing requirements under
the EAPA.
In NSW, pet stores are subject to the regulations of POCTA and the Animal Welfare Code of Practice – Animals
in Pet Shops (Pet Shop Code).105 The Pet Shop Code recognises that animals in pet stores are limited in
relation to their physical and social environments, and therefore there is a greater responsibility towards those
animals and their environment.106 Animals kept in pet store displays are subject to confined enclosures, which
are erected for the purpose of proper viewing for buyers.107 There are no regulations as to the length of time
periods that animals can be kept in pet stores, or unaccompanied overnight/during closed periods, nor any
consideration of key socialisation periods for young animals.
The Committee submits that also regulating the action of displaying animals for the purpose of sale, rather
than just the outcome of animal cruelty under POCTA is the most efficient way of ensuring strong animal
welfare outcomes, noting the sentient nature of animals.108
Under the Exhibited Animals Protection Act 1986 (EAPA), a license will not be issued unless an animal display
establishment conforms to the standards prescribed.109 The Committee submits that applying these standards
to organisations such as pet stores and market sellers will deter the commercial sale of animals in pet stores.
104 Exhibited Animals Protection Act 1986, s 5 definition of “exhibit.”
105 NSW Department of Primary Industries, Animal Welfare Code of Practice: Animals in Pet Shops (2008).
106 Ibid, Preface.
107 See above, n 13.
108 See the Committee’s response to Question 1 of this submission.
109 Exhibited Animals Act 1986 (NSW), s 15(1).
NSWYL Animal Law Committee | Consultation on NSW Animal Welfare Reform - Issues Paper | June 2020
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